whistleblowing system [2-16], [2-25], 2-26]
Up to the end of 2024, the Company had yet to implement a formal mechanism to run a whistleblowing system. However, the function of receiving, investigating, handling and resolving grievances or whistleblowing reports on any violation of the Company’s rules or any regulations pertinent to the Company’s business, is currently carried out by the Internal Audit Unit. The Internal Audit Unit maintains confidentiality and protects the identity of the reporters or whistleblowers within reasonable bounds and in accordance with Law No. 31/2014 on Witness and Victim Protection.
Scope of Reporting
Complaints submitted through the whistleblowing system may include information or indications of fraud and negligence occurring within the Company, which can be reported by employees or the public. The following types of complaints can be followed up by the whistleblowing system management team, including:
1. Fraud
2. Fraudulent activities
3. Embezzlement of assets
4. Information leakage
5. Criminal actions and
6. Other similar actions
Media for Submitting Complaints
The public can submit their reports via:
E-mail: corporate.secretary@mcash.id
Phone Number: +6221-8062-3767
Report Submission Method
The reporting party who reports violations or fraudulent actions is requested to provide the following complete information:
1. Name of the reporter
2. Department or division of the reporter (If the reporter is a company employee)
3. Contact number of the reporter and
4. Email address (If available)
This information should be submitted along with the report through the available reporting channels.
Whistleblowing Administrator
The results of the handling of grievances or whistleblowing reports are reported by the Internal Audit Unit to the President Director and the Audit Committee, to be used as a consideration by management for future improvement. In 2024, the Company received no reports of violations, either those that occurred in the Company's internal or external environment.
Protection for Whistleblowers
The Company is committed to providing support and protection to every whistleblower as well as maintaining the confidentiality of their identity and reports. Support and protection that can be provided to whistleblowers are as follows:
1. Protection of the confidentiality of the identity of the reporter and the case reported
2. Whistleblowers are protected from actions by the reported party, including pressure, postponement of promotion, dismissal, lawsuits, threats to property, physical actions and detrimental records in personal data files
3. Sanctions may be reduced if the whistleblower is involved in the reported case
4. Internal Audit is required to monitor and report to the President Director or the Audit Committee any issues regarding whistleblower protection
Whistleblowing Management
1. If the whistleblower has evidence in the form of data or information on a violation, it should be included when reporting
2. Each reporter must have a strong reason for submitting a report of a violation or potential violation and must act in good faith (Not with slanderous intent) and without seeking personal gain or having other motivations
3. Every violation report should, at minimum, contain the following information to expedite the handling process:
a. Types of violations and their sequence of events
b. The parties involved
c. Location of the incident
d. Time of occurrence
e. Availability of evidence pertaining to the violation
4. If Internal Audit receives a report accompanied by the whistleblower’s identity, Internal Audit is required to ask their willingness to be a witness. If the whistleblower were unwilling, then they cannot be used as a witness in the next stage of legal action
5. Reports from whistleblowers will be reviewed and verified by Internal Audit. Subsequently, the report will be discussed with the President Director for assignment to the investigation process or further action
6. In general, the Company will follow up on reports received from whistleblowers. However, the Company may choose to discontinue a report if it is strongly suspected of containing the following elements:
a. Does not specify the type of violation as determined
b. Made in bad faith
c. Has a specific purpose for personal or group interests
7. If the whistleblower provides their identity, Internal Audit will contact them regarding the submitted report and inform them whether the report will be followed up or cannot be pursued
Results of Complaint Handling and Follow-up
No reports were received through the whistleblowing system in 2024. All reports through the whistleblowing system in 2024. All reports have been processed and followed up in accordance with the applicable regulations.